Taxes Management Act 1970 section Sch 3ZB para 6

Interpretation: exit charge assets and liabilities

Section Sch 3ZB paragraph 6 defines and categorises the different types of exit charge assets and liabilities that can arise when a company migrates its permanent establishment out of the UK.

• Exit charge assets and liabilities are PE qualifying assets or liabilities that generate income, profits or gains during the migration accounting period as a result of exit charge provisions
• These are split into three categories: TCGA or trading stock exit charge assets (covering capital gains and trading stock but excluding pre-Finance Act 2002 intangible fixed assets), financial exit charge assets or liabilities (covering loan relationships and derivative contracts), and intangible exit charge assets
• Intangible exit charge assets include both assets taxed under the intangible fixed assets regime and pre-Finance Act 2002 intangible fixed assets that would otherwise fall under the capital gains rules
• A pre-Finance Act 2002 intangible fixed asset is one that qualifies as a pre-FA 2002 asset under section 881 of the Corporation Tax Act 2009, meaning it was held before the intangible fixed assets regime came into effect